Route66 and CallThree – Privacy Policies & Notices

Aug. 5, 2023

Route66 and CallThree – Privacy Policies & Notices

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If you are a visually impaired customer, a customer who has another disability or a customer who seeks support in other languages, you may access this Privacy Policy by emailing us at support@callthree.com.

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Our Privacy Commitment to You

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First, a note about callthree and Route66 commitment to your privacy.

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callthree and Route66 deeply values its role as a trusted provider of meditation, mindfulness and mental health offerings through the callthree and Route66. callthree and Route66 provides meditation and mindfulness content for stress, sleep, focus, and movement, and Ginger provides on-demand mental health support through coaching, therapy, psychiatry, and self-care resources. outside of the Singapore, please contact us at support@callthree.com. 

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1. We only collect the personal information we need in order to provide you with callthree and Route66 Health’s services and products. We do not collect more information than we need. The personal information that we ask you to provide us, or give you the option to provide us, is intended to help us direct you to and deliver meditation, mindfulness, and mental health-related services, as applicable, that adhere to our standards of high quality and exceptional member service.

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1. We do not use your personal information for purposes unrelated to the reasons for which it was collected, or that would not conform to your reasonable expectations.  We know it is important to you that you be aware of all the reasons that your information is collected, used and shared by callthree and Route66 Health. Our responsibility to safeguard your privacy is of the utmost importance to us.

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1. We do not retain personal information for longer than is necessary.  We understand the importance of minimizing the personal information that we may maintain.  We will only retain your data for the period of time necessary to fulfill the purposes for which it was collected, including delivering requested products and services, protecting the interests of our users and other stakeholders, and as otherwise consistent with our legal obligations or your reasonable expectations.

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1. We do not sell your personal information to others.  We will not sell your personal information to third parties, except to the extent that our sharing of personal information to facilitate targeted digital advertising may be considered “selling” or “sharing” your personal information under certain state laws.

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1. We offer you ways to control your personal information and express your preferences.  We provide you with a variety of ways to exercise control over your personal information, including providing you with options regarding what personal information you provide to us, exercising your account and communications preferences, and updating your user profile. You may have other rights depending on your location and applicable law.

callthree and Route66 Health Privacy Policy

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callthree and Route66 Health (callthree and Route66 Health entities include callthree and Route66, Inc., Ginger.io, Inc. and its subsidiaries and affiliates, collectively referred to as “callthree and Route66 Health,” “us,” “we,” or “our”) is committed to protecting and respecting your privacy in connection with your use of our websites, including www.callthree and Route66health.com, www.callthree.com, and www.ginger.com (the “Websites”) and the products, services and features that may be referenced on the Websites or otherwise offered by callthree and Route66 Health (our “Products and Services”). These include but are not limited to our mobile applications and administrative tools related to our callthree and Route66 Health mental health offerings, including the websites and mobile apps offered by callthree and Route66 and Ginger, and the products and services offered through those respective sites and apps (“callthree and Route66 App” and “Ginger App” respectively), collectively for purposes of this Privacy Policy referred to as the “callthree and Route66 Health Platform” or “Platform,” which may be updated from time to time at the sole discretion of callthree and Route66 Health.

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This privacy policy (“Privacy Policy”) and any other documents referred to herein cover personal information collected through the callthree and Route66 Health Platform and in connection our Products and Services.  We may provide additional privacy disclosures regarding the Websites, callthree and Route66 App, and/or Ginger App, and the products and services offered through those respective sites and apps, and we encourage you to please review the callthree and Route66 Privacy Policy and Ginger Privacy Policy for those disclosures, as well as the callthree and Route66 Cookie Policy for more information about our use of cookies and other tracking technologies. We also encourage you to review our other terms and notices, including: 

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• callthree and Route66 Terms and Conditions regarding your use of the callthree and Route66 Website and Apps
• Ginger Terms of Service regarding your use of the Ginger Website, Services, and App

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If you are based in the Singapore and engage with the Ginger App and related services in connection with coaching and mental health services, we may collect or receive certain personal information and other data about you that is governed by federal or state health privacy laws, such as the Health Insurance Portability and Accountability Act (“HIPAA”) and California Medical Information Act (“CMIA”).  Please review our Notice of Privacy Practices, which governs our use, disclosure and access to information protected by HIPAA. This Privacy Policy does not intend to include information about how we handle HIPAA-regulated personal health information (“Protected Health Information”, “PHI”).

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Please also note that residents of certain jurisdictions may have certain unique rights with respect to our collection, use, and sharing of personal information, including residents of California, the European Union, and the United Kingdom. Please refer to Sections 10 and 11 for information about these jurisdiction-specific rights. 

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Please read the following carefully to understand our practices regarding your personal information and how we will collect, use and disclose your personal information.

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Linkable Table of Contents

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This Privacy Policy is provided in a layered format. You can jump to a specific section by clicking on the section below:

1. Collection of personal information

We may collect your personal information when you interact with us through the callthree and Route66 Health Platform, share your information with us, or by other means. We may also automatically collect information regarding your use of our Platform.

1. Use of personal information

We may use your personal information for various purposes connected with your interest in the callthree and Route66 Health Platform, and our Products and Services, and to allow us to maintain and improve them.

1. Sharing of personal information

We may share your personal information with certain third parties, such as with our service providers, as directed by you, and to provide you with opportunities that we believe may be of interest to you.

1. Your rights and choices

You may have certain rights and choices regarding our collection, use, and disclosure of your personal information.

1. Data security 

The security of your personal information is of utmost importance to us and we maintain appropriate safeguards to protect it.

1. Cookies and tracking technologies

When you visit the callthree and Route66 Health Platform, we may collect certain information from you automatically through cookies and other tracking technologies.

1. Children’s privacy

Our Platform is intended for individuals at least 18 years old or older, except in limited circumstances that will be clearly described to you. 

1. International data transfers

Our Platform is operated exclusively in the Singapore.

1. Likes to other websites

Our Platform may contain links to other websites that are not operated by us and that are subject to third party privacy policies and other terms.

1. California Privacy Notice

We provide additional disclosures and rights to California residents.

1. European and UK Privacy Notice

We provide additional disclosures and rights to individuals located in Europe and the United Kingdom.

1. Changes to this Privacy Policy

We may change this Privacy Policy from time to time to reflect new services or changes in our data practices or relevant laws.

1. Contact us

You may contact us for comments or questions in various ways.

1. Collection of personal information

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For purposes of this Privacy Policy, “personal information” means any information that relates to an identified or identifiable individual. The personal information we collect through the callthree and Route66 Health Platform will be apparent by the context of the page and/or the circumstances in which the personal information is being collected. This may include collection and processing of personal information including, but not limited to, the following categories of information.

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1.  Information you provide to us

callthree and Route66 Health may collect the following categories of personal information about you that you choose to provide to us when you use the callthree and Route66 Health Platform or otherwise interact with or receive our Products and Services:

• Contact information and identifiers.  When you use our Platform, we may ask you to provide certain contact information including your first and last name and email address. We may also collect your social media identification number if you choose to access the Platform via a social media platform. 
• Account Information. If you decide to set up an account with us, we may ask you to provide certain additional contact information including, for example, your first and last name, e-mail address (personal and/or work), telephone number, mailing address, employer or company name, job title, student identification number, emergency contact information, as well as password and other authentication-related information. For individuals who participate in a special subscriptions and features, including group plans, we may collect additional personal information, for example, home address and names and emails of household members for example, the names and emails of household members.
• Surveys, health, and medical information.  We may present you with surveys or other information forms on our Platform order to provide you with information about our Products and Services that we think may be of interest to you or for research purposes. These surveys may give you the opportunity to describe certain things about you, such as your current mental, emotional, and physical status, wellness goals, current life events, and other health-related information.
• Profile and demographic information.  Through your account on our Platform, including the callthree and Route66 and Ginger Apps, you may have to opportunity to provide additional information about yourself, such as your age, race and ethnicity, sexual orientation, preferred pronouns, gender or gender identity, sex at birth, marital status, and details about your health and medical history. 
• Payment information.  If you sign up for a paid product or service from us, you may be required to provide your payment card or bank account information.  Please note that callthree and Route66 Health does not directly process payment card information, but does rely on third party payment processors to do so on our behalf. Please note that third party terms may apply to these payment services. Personal information collected for these purposes includes card number, type, expiration date, and billing address, and certain anonymized, limited and/or truncated versions of this information may be provided to callthree and Route66 Health.
• Communication information.  When you send or respond to emails, messages, or other communications from callthree and Route66 Health, we may collect your email address, name, and any other personal information you choose to include in the body content of your communications. In addition, when you interact with certain  features of our Platform, we may collect the content of those communications.

1. Information from others

In certain circumstances, we may collect personal information from others. This may include the following:

• If you receive access to callthree and Route66 Health through your employer, health plan, or other callthree and Route66 Health Partner, we collect your name and email address and demographic information that such Partner submits to us to facilitate your enrollment in our programs. 
• We may collect the name, email address, content engagement, and  preferences of individuals that our users identify through our sharing and referral features. We use this data for the sole purpose of sharing content and referring individuals to join the Products. 
• We may collect personal information from parents or guardians who wish to enroll their adolescent dependents ages 13-17 in our Ginger for Teens offering. We will use this data to enroll the teen.  
• If you choose to have your account verified to confirm your eligibility for a select subscription offering, we may allow a third party platform to access the specific personal information you provide in order to perform the verification. Any failure to provide sufficient information or any response callthree and Route66 considers abnormal may result in callthree and Route66 refusing (or being unable) to verify your eligibility

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If you would like us to delete personal information that may have been provided to us by others as described above, you can do so by opting out as described in the invitation or other communication that we may have sent to you, or by contacting us at support@callthree.com.

1. Information we automatically collect

Our Platform, including the Websites, may collect information from you automatically as your use our Platform, including individual Websites and Apps  This information may include: 

• Browser and device data, such as IP address, device identifier, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons, and the language version of the Websites and Apps you are visiting; and
• Usage data, such as geolocation data, browsing history, time spent on the Platform, pages visited, links clicked, language preferences, performance of features, patterns of use, and the pages that led or referred you to our Platform including individual Websites and Apps.  For example, we use Google Analytics on our Websites to help us analyze your use of our Websites and diagnose technical issues.
• Cookies and web-beacons  We may use cookies and other tracking technologies such as pixels, web beacons, embedded scripts, and tags (“Cookies”). We also collect information about your online activities on websites and connected devices over time and across third-party websites, devices, apps, and other online features and services. 

Please review our Cookies and tracking technologies section below, as well as our Cookie Policy  for more information about our use of these technologies.

1. Aggregated, anonymous, and de-identified data

We may create aggregated, anonymous, or de-identified data from personal information by removing data components that make the data personally identifiable to you, or potentially personally identifiable to you, or through obfuscation or other means. Once information is aggregated, anonymized, or de-identified such information is no longer personal information, and use of the data is not subject to this Privacy Policy.

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1. Use of personal information

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We may use your personal information in the following ways:

• To provide our Products and Services, including the delivery of content and facilitation of interactive features;
• To communicate with you regarding the callthree and Route66 Health Platform, Products and Services;
• To notify you about updates or changes to the callthree and Route66 Health Platform, Products and Services;
• To provide customer service, answer your questions or requests for information, or handle your complaints;
• To facilitate payment transactions, manage your orders, and account for applicable sales taxes;
• To inform businesses, government entities, hospitals, universities and other organizations and groups that wish to make our Products and Services available to their members, employees and their families, patients, customers, residents or others (collectively, our “Partners”) about your registration and, in limited cases, use of the Products and Services;
• To effectuate our performance on any agreements that we may have with you;
• To maintain and improve the quality of the callthree and Route66 Health Platform, Products and Services, including to perform research and development, understanding our user trends, and understand the effectiveness of our marketing and advertising;
• To provide you with information about new Products and Services, promotions, and other opportunities that we believe may be of interest to you, whether offered by us or third-party partners, and to personalize, measure, and improve such offers;
• To serve our advertisements to you through third-party platforms, such as Facebook or Google, on other sites and apps or across your devices, to the extent that you have provided consent and/or consistent with notice and any opt-out rights for such uses under applicable law;
• To protect ourselves, you and others; preventing fraud and other unlawful or unauthorized activity; and creating and maintaining a trusted, secure, and reliable online environment; and
• To comply with our legal obligations; respond to subpoenas, court orders or legal process; and to establish or exercise our legal rights or defense against legal claims.

Please note that we may also use your personal information to cross-reference or convert various types of accounts that you may be associated with on our Platform. For example, we may cross reference the account information you provide to ensure your access to both callthree and Route66 and Ginger using the same credentials. 

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1. Sharing of personal information

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We may share your personal information with any member of our group, which includes callthree and Route66, Inc., Ginger.io, Inc. and our subsidiaries and affiliates, for any of the purposes described in this Privacy Policy. 

We may also disclose your personal information with the following categories of third parties:

• Our service providers. In some circumstances, based on your specific requests, we may need to disclose your personal information to a third party so that they can provide a service on our behalf, such as to help deliver Products or Services that you have requested. These service providers may include services such as analytics , payment processing, advertising and marketing, website hosting, customer and technical support, and other services. 

Our service providers have access to your personal information only to perform these tasks on our behalf and are obligated to maintain the confidentiality and security of your personal information, and to not disclose or use the information for any other purpose, consistent with this Privacy Policy and applicable law.

• Third party advertising platforms. We may share your personal information with third party platform providers who assist us in serving advertising regarding the callthree and Route66 Health Platform, Products and Services to others who may be interested.  We also partner with third parties who use Cookies to serve interest-based advertising and content on their respective third-party platforms that may be based on your preferences, location and/or interests.
• Our Partners. In limited cases, we may provide certain personal information to our Partners, which may include your employer, in order to provide the callthree and Route66 Health Platform, Products and Services as a benefit of your employment.
• Third party business partners. In limited cases, we may provide certain personal information to third party businesses with which we have a joint promotional relationship or other trusted partnership. This type of sharing will most often be consistent with your notice, consent, direction, and/or reasonable expectations in light of the circumstances in which you provided the personal information.
• Compliance and harm prevention. If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, such as to comply with a subpoena, bankruptcy proceeding, similar legal process, or in order to enforce or apply our agreements with you; or to protect the rights, property, or safety of callthree and Route66 Health, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction. We may also disclose personal information where we believe that doing so would be in accordance with or required by any applicable law, regulation or legal process
• Affiliate and business transfer. If callthree and Route66 Health, including any of its subsidiaries, brands or affiliates, is involved in a merger, acquisition, asset sale, or other corporate combination, your personal information may be transferred to the acquiring or surviving entity. If such transfer results in a material change to the use of your personal information, we will provide notice before your personal information is transferred and/or becomes subject to a different privacy policy.

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1. Your Rights and Choices 

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You may have rights and choices regarding our use and disclosure of your personal information. Unless instructed otherwise, you can exercise these rights and choices using the information in the Contact us section at the end of this Privacy Policy.

1. Privacy rights, choices, and preferences. If you have an account on our Platform, please visit your account for any privacy rights, choices, or preference options that may be offered. In your callthree and Route66 Health user profile, you are able to make additions or edits to any of your personal, payment, or membership information, and you may request to delete your account. You may also submit a request to support@callthree.com. For more information about your available privacy rights in certain jurisdictions for both accountholders and non-accountholders, please review our Singapore Privacy Notice and European and UK Privacy Notice in the sections below.
2. Opting out of receiving electronic communications from us. You will not receive promotional electronic communications from us if you have opted out of receiving such communications. If you wish to opt out, you may opt out via the unsubscribe link included in such emails or by contacting us at support@callthree.com. We will comply with your request as soon as reasonably practicable. Please note that if you opt out of receiving promotional emails from us, we may still send you important administrative messages that are required in order to provide you with our Products and Services or for other reasons disclosed in this Privacy Policy. For EU-based users only, we will ask for your consent prior to sending you any promotional electronic communications. 
3. Your Nevada privacy rights. Nevada residents have the right to request to opt out of any “sale” of their personal information under Nevada SB 220. We do not currently sell personal information under Nevada law; however, you may still request to opt out of the future sale of your personal information. If you are a Nevada resident and would like to make such a request, please contact us using the information in the Contact us section at the end of this Privacy Policy, and provide “Nevada Privacy Rights” in the subject line. You must include your full name, email address, and postal address in your request so that we can verify your Nevada residence and respond. In the event we sell your personal information after the receipt of your request, we will make reasonable efforts to comply with such request.

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1. Data security 

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The security of your personal information is important to us. We follow generally accepted standards, practices, and procedures to protect the personal information submitted to us, both during transmission and once it is received. We maintain appropriate technical, administrative and physical safeguards to help protect the security of your personal information against unauthorized access, destruction, loss, alteration, disclosure or misuse.  

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If you have an account with us and you suspect unauthorized use of your account or its credentials, you should notify us immediately using the information in the Contact Us section at the end of this Privacy Policy.

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1. Cookies and tracking technologies 

When you visit the callthree and Route66 Health Platform, we may collect information from you automatically through Cookies. We also rely on service providers and other partners to provide many features of our Platform using data about your use of the Platform, which may include personal information. Please review the Cookie Policy for more information regarding our collection of Cookies, the purposes for which we use them, and how to exercise your preferences regarding them including the ability to opt-out through our Platform or via your browser.

The callthree and Route66 Health Platform uses Google Analytics code to gather statistical data. Google Analytics sets cookies to help us accurately estimate the number of visitors to the Platform and the volumes of usage of the Products and Services. This is done to ensure that the Platform and its associated Products and Services are available when you want them and are fast. For more data on how Google Analytics processes this data, visit www.google.com/analytics.

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We will acquire consent from you in order to use such trackers or provide you with the opportunity to opt-out of such trackers, to the extent required by applicable law. For more information on the types of cookies used by callthree and Route66 Health and your ability to restrict the behavior of cookies or disable them in your browser’s settings, please refer to the Cookie Policy.

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We do not support Do Not Track functionality. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

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Other tracking on our Platform.  Our Platform, including our Websites, may utilize tracking technologies to collect and record your activities and movements across our Websites throughout your browsing session, including to track button clicks, mouse movements, scrolling, resizing, touches, keystrokes, data entered, device information and orientation, browser visual elements, and screen size (“Session Data”), for purposes of our own internal analytics and improving our products, services, and user experience. Such tracking may include recorded sessions, which we may play back for these purposes.

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Our Platform also utilizes live chat and/or chat bot technology, which visitors to communicate directly with our automated customer service system and/or customer service representatives via a chat window about our Products and Services. Text entered into this form prior to submission may be collected, retained, and used by callthree and Route66 Health for our business purposes, including by our customer service and other personnel and service providers.

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We may share Session Data and chat bot correspondence data with our third-party analytics or service providers, which may change from time-to-time, for these purposes, who will use the data solely on the behalf of, and for the benefit of, callthree and Route66 Health. 

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1. Children’s privacy

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Our Platform is intended for individuals at least 18 years of age, or the age of majority in your province, territory or country. Individuals ages 13 of 18, or the applicable age of majority, may utilize the callthree and Route66 Health Platform only with the consent and involvement of a parent or legal guardian. This provision is not applicable to registrations made under select subscriptions or special offerings, including business to business sales and enterprise partnerships, where specified in applicable contracts.

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If you are a parent or guardian and you are aware that a child under age 13 has provided us with personal information without parental consent, please contact us at support@callthree.com. If we become aware that we have collected personal information from children under age 13 without parental consent, we will take steps to remove that information from our servers.

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1. International data transfers

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The callthree and Route66 Health Platform is operated exclusively in the Singapore. To the extent callthree and Route66 Health offers Products and Services to individuals located in the European Union or United Kingdom, or to the extent the callthree and Route66 Health Platform is intentionally available to such individuals, please review our European and UK Privacy Notice below for more information about disclosures and privacy rights associated with that activity.  

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The subsidiaries, service providers or other third parties described in this Privacy Policy and to whom callthree and Route66 Health may disclose your personal information may be domiciled abroad, and, in particular, outside the European Union and the United Kingdom. In such case, callthree and Route66 Health will require them to take, in accordance with applicable legislation, contractual, organizational and technical measures designed to ensure an adequate level of protection of your personal information, such as the use of Standard Contractual Clauses approved by the European Commission.

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We remain certified under the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield (https://www.privacyshield.gov/) and are committed to the important privacy principles set forth in Privacy Shield. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List. https://www.privacyshield.gov/list.

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However, in light of the Schrems II decision by the European Court of Justice on July 16, 2020, we are no longer relying exclusively on EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield and have implemented other transfer mechanisms such as Standard Contractual Clauses to address any transfers of personal information to the U.S., consistent with applicable law.

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For personal information collected from individuals located in the European Union, Switzerland and the United Kingdom, you have the ability to opt out of whether such personal information is disclosed to a third-party (apart from service providers) or is to be used for a purpose that is materially different for the purpose for which it was originally collected or subsequently authorized. You can contact callthree and Route66 Health at support@callthree.com in order to make such choices.

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General disputes arising from your use of the callthree and Route66 Health Platform, as well as our Products and Services, can be found in our Terms & Conditions. However, if you have any questions or concerns regarding our information collection, use, and sharing practices as described in this Privacy Policy, you may reach us using the Contact us section at the end of this Privacy Policy and we will investigate the matter and resolve any issues, if we can. In the event that we are unable to resolve any such questions or concerns, you may be able to invoke binding arbitration, under certain conditions and as permitted by Privacy Shield, by contacting our U.S.-based third party dispute resolution provider (free of charge) at http://go.adr.org/privacyshield.html. callthree and Route66 Health is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (“FTC”).

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callthree and Route66 Health is mindful of its responsibility and potential liability for onward transfers of personal information to third parties where callthree and Route66 Health deems such transfers necessary and those transfers are subject to Privacy Shield.

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1. Links to other websites

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Our Platform, including its Websites and Apps, may contain links to other websites that are not operated by callthree and Route66 Health. We are not responsible for the content or privacy policy policies of websites we do not own or control, and our Privacy Policy does not apply to third-party websites. We strongly suggest you review the privacy policies for third-party websites to understand how your personal information is used and stored by those websites.

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1. California Privacy Notice

This California Privacy Notice supplements information contained in our Privacy Policy and applies to any California residents about whom we have collected personal information from any source, including offline, and through your use of the callthree and Route66 Health Platform.

We provide this California Privacy Notice to comply with applicable privacy laws in the State of California, including the California Consumer Privacy Act of 2018, and its amendment, the California Privacy Rights Act of 2020 (together, the “CCPA”). Any capitalized term used and not otherwise defined below has the meaning assigned to it in our Privacy Policy. 

The CCPA provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of personal information, as well as rights to access, delete, correct, limit, and opt-out of the sales of certain personal information we collect about them, as well as to opt-out of the sharing of certain personal information for purposes of cross-context behavioral advertising (called “sharing” under California law). California residents also have the right not to receive discriminatory treatment by us for the exercise of your privacy rights under the CCPA. If you are a California resident, you may submit a request to exercise these rights by emailing us using the information provided in the Your Privacy Rights section below. 

For the purposes of this California Privacy Notice, except where a different definition is noted, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available information; lawfully obtained, truthful information that is a matter of public concern; information that has been de-identified; or information that has been aggregated. For purposes of this section, “publicly available information” includes: information that is made available from federal, state, or local government records; information that a business has a reasonable basis to believe is lawfully available to the general public, either through widely distributed media, or by the consumer; and information that is made available by a person to whom the consumer has disclosed the information if the consumer has not restricted the information to a specific audience.

For our CCPA disclosures with respect to callthree and Route66 Health’s collection, use and disclosure of personal information for employment-related purposes, as well as what privacy rights may be exercised as to such information, please review our California Employee Privacy Policy.

1. Personal information we collect

callthree and Route66 Health may collect, or has collected, the following categories of personal information from California residents within the last twelve (12) months:

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Please note that because of the overlapping nature of certain of the categories of personal information identified above, which are required by state law, some of the personal information we collect may be reasonably classified under multiple categories.

Sensitive personal information.  Certain of the personal information that we collect, as described above, may constitute “sensitive personal information” under California law, including: 

• Account log-in, financial account, debit card, or credit card number combined with any required security or access codes, passwords, or other credentials allowing access to an account;
• Precise geolocation;
• Racial and/or ethnic origin, religious or philosophical beliefs, or union membership;
• Personal information concerning health; and
• Personal information concerning sex life or sexual orientation.

The specific types of personal information we collect are further detailed in Section 1 of this Privacy Policy. Personal information does not include information excluded from the CCPA’s scope.

callthree and Route66 Health will not retain any information we collect about you for longer than is reasonably necessary for the disclosed purpose of using such information. Our determination of precise retention periods will be based on (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations). 

1. Uses of personal information

callthree and Route66 Health may collect, use, or disclose personal information about California residents for purposes listed in Section 2 of our Privacy Policy.

The sensitive personal information that we collect as described in Section 10(a) above may be used for any of the following purposes:

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PURPOSE

CATEGORY OF SENSITIVE INFORMATION USED

To provide our Products and Services, including the delivery of content and facilitation of interactive features

Account log-in, financial account, debit card, or credit card number combined with any required security or access codes, passwords, or other credentials allowing access to an account; Precise geolocation; Racial and/or ethnic origin, religious or philosophical beliefs, or union membership; Personal information concerning health; and Personal information concerning sex life or sexual orientation

To communicate with you regarding the callthree and Route66 Health Platform, Products and Services

Precise geolocation.

To facilitate payment transactions, manage your orders, and account for applicable sales taxes

Account log-in, financial account, debit card, or credit card number combined with any required security or access codes, passwords, or other credentials allowing access to an account

To maintain and improve the quality of the callthree and Route66 Health Platform, Products and Services, including to perform research and development, understanding our user trends, and understand the effectiveness of our marketing and advertising

Racial and/or ethnic origin, religious or philosophical beliefs, or union membership; Personal information concerning health; and Personal information concerning sex life or sexual orientation; precise geolocation.

1. Sources of personal information 

We obtain the categories of personal information listed above from the following categories of sources:

• From you, including, for example, from forms you complete when registering for the callthree and Route66 Products and Services, surveys that you take, or as automatically collected when using our Platform.
• Through our service providers, which are third party companies who help us provide Products and Services to you consistent with the purposes disclosed in this Privacy Policy.
• Directly from Partners for select subscriptions that are verified as described in the callthree and Route66 Privacy Policy.
• From our business partners and others, including those that may promote and/or offer products and services that may be of interest to you.

We may supplement the personal information collected from the categories of sources described above with personal information we obtain from other sources.

1. Disclosure of personal information 

We may disclose your personal information to the categories of service providers and third parties identified in Section 3 of this Privacy Policy, and in ways that are described in that section.

This includes disclosure of your personal information to service providers for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not to use it for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed each categories of personal information listed in Section 10(a), including the listed sensitive personal information, for a business purpose.  

callthree and Route66 Health does not “sell” personal information to third parties for monetary or other valuable consideration as that term is defined by the CCPA as amended by the CPRA. 

However, we do “share” personal information for purposes of cross-context behavioral advertising, as that term is defined by the CCPA. Specifically, as with many online companies, callthree and Route66 Health partners with third parties, such as Facebook and Google, to manage our marketing of callthree and Route66 Health on other platforms, where such advertising is based on your past visits to our Platform. These third party partners may use technologies, such as Cookies, to gather information about your activities on the Platform to deliver such advertising to you when you visit their platforms. For instance, if you visit www.callthree.com, a cookie may be attached to your browser in the form of the Facebook Pixel that allows callthree and Route66 Health to deliver advertising to you on the Facebook platform.  Please also review our disclosures in Section 6 of our Privacy Policy (“Cookies and other tracking technologies”).  

The CCPA requires us to identify the categories of personal information that we have “sold” or “shared” under the CCPA in the preceding twelve (12) months.  

In the last twelve (12) months, we have disclosed (or “shared”) the following categories of personal information to advertising partners for cross-context behavioral advertising purposes:  

• Identifiers
• Internet or other electronic network activity information

1. Your privacy rights 

The CCPA provides California residents with specific privacy rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

If you are a California resident, you have the right to make the following requests under applicable California law in relation to your personal information, subject to certain exceptions:  

• Right to Know.  You have the right to, up to twice in a 12-month period, request what personal information we collect, use, disclose, and/or sell, and to whom, as applicable. You may request either a report disclosing the general categories of the personal information we collect, or a report disclosing the specific pieces of personal information we collect.
• Right to Delete.  You have the right to request, under certain circumstances, the deletion of your personal information that we collect.
• Right to Opt-Out of Sale or Sharing.  You have the right to opt-out of the “sale” or “sharing” of your personal information, as those terms are defined under California law. Please note that callthree and Route66 Health does not currently sell your personal information, though it does “share” your personal information with third parties for cross-context behavioral advertising as disclosed elsewhere in this section.   
• Right to Non-Discrimination.  You have the right not to receive discriminatory treatment for the exercise of the privacy rights described above.  
• Right to Limit Use and Disclosure.  You have the right to limit the use or disclosure of your sensitive personal information to only the uses necessary for us to provide our Products and Services to you, or for certain other authorized purposes. We will not use or disclose your sensitive personal information after you have exercised your right unless you subsequently provide consent for the use of your sensitive personal information for additional purposes.
• Right to Correct.  You have the right to request the correction of your inaccurate personal information.

How to submit a request. To submit a request of any of the rights described above, please submit a verifiable consumer request to us by either:

• Emailing us at support@callthree.com
• Calling us at 855-432-3822

Any request you submit to us is subject to an identification and residency verification process (“Verifiable Consumer Request”) as permitted by the CCPA.  We will not fulfill your request unless you have provided sufficient information that enables us to reasonably verify that you are the consumer about whom we collected the personal information on.  In order to verify you, you must provide us with your first and last name and email address.  

Requests by authorized agents.  You may designate an authorized agent, in writing or through a power of attorney, to request to exercise the above rights on your behalf. If you should use an authorized agent to exercise your various rights under the CCPA, we may require that you provide your authorized agent with written permission to exercise your various rights and to verify your own identity with us. If your authorized agent does not submit proof that they have been authorized by you to submit verified requests for disclosure and deletion, we reserve the right to deny such a request that we have received and will explain to your authorized agent why we have denied such request. The authorized agent may submit a request to exercise these rights by emailing the letter of authorization or power of attorney to support@callthree.com.

Household data.  We collect household data in connection with our family plans. If we receive a Request to Delete, Know, or Correct submitted by all members of a household, we will individually respond to each request consistent with California law. If we receive a Request to Opt-Out or Limit submitted by all members of a household, we will process the request based on the information we have about your household and the individuals associated with it, and reserve the right to ask for further information if we determine it is needed to fully process your request. We will not be able to comply with any such request by a member of a household under the age of 13, as we do not collect personal information from any person under the age of 13.

Responses.  We will respond to your request within forty-five (45) days after receipt of a Verifiable Consumer Request for a period covering twelve (12) months and for no more than twice in a twelve-month period.  callthree and Route66 Health reserves the right to extend the response time by an additional forty-five (45) days when reasonably necessary and provided consumer notification of the extension is made within the first forty-five (45) days.

These rights are subject to various exclusions and exceptions under California law and other applicable laws. In addition, if we are unable to verify your identity to a degree of certainty as required by the CCPA through any reasonable method, we will state that we are unable to verify in a written response to you along with a reason as to why there is no reasonable method by which we can verify your identity. 

Direct marketing by third parties.  callthree and Route66 Health does not disclose personal information to third parties for their own direct marketing purposes. However, California residents additionally have the right to request information regarding such practices under California’s “Shine the Light” law. If you are a California resident and would like to inquire further, please email support@callthree.com.

We will continue to update our business practices as direct regulatory guidance becomes available.  

1. Notice of Right To Opt-Out

As detailed in Section 10(d) above, callthree and Route66 Health does not “sell” personal information to third parties for monetary or other valuable consideration as that term is defined by the CCPA as amended by the CPRA. However, callthree and Route66 Health does “share” personal information with third parties for purposes of cross-context behavioral advertising, as that term is defined by the CCPA.

If you wish to opt-out of the “sharing” of the limited data that is gathered when you visit our Platform for purposes of cross-context behavioral advertising, please visit the Cookie Policy and click “opt-out of marketing / analytics cookies” at the bottom of the page. Doing so will erase all current marketing cookies and disable the placement of future marketing cookies.

1. European and UK Privacy Notice

This European and UK Privacy Notice applies to any individuals located within the European Economic Area (EEA) or the United Kingdom (UK) from whom we may have collected personal data from any source, whether online or offline, including through your use of our Websites. We provide this European Privacy Notice to comply with applicable privacy laws, including the General Data Protection Act (“GDPR”), the UK GDPR, and related laws, regulations, and guidance from the European Union and/or its member states.  Any capitalized term used and not otherwise defined below has the meaning assigned to it in our Privacy Policy. 

European law provides individuals located in Europe with rights to receive certain disclosures regarding the collection, use, and sharing of personal data, as well as rights to be informed, to access, to rectification, to erasure, to restrict processing, to data portability, and to object with respect to collected personal data.  For the purposes of this European and UK Privacy Notice, “personal data” means any information relating to an identified or identifiable natural person.

1. Basis for processing your personal data

callthree and Route66 Health relies on one or more legal bases to process your personal data under applicable law.  We may process personal data (i) as necessary to perform our contractual obligations to you; (ii) as necessary to pursue our legitimate interests as further detailed below; (iii) as necessary for our compliance with our legal obligations such as a request or order from courts, law enforcement or other government authorities; and/or (iv) with your consent, including to send you marketing email messages and other information that may be of interest to you, which you may withdraw at any time.

Legitimate business interests.  We may collect, process, and maintain personal data to pursue the legitimate business interests outlined below.  To determine these legitimate interests, we balance our legitimate interests against the legitimate interests and rights of you and others, and only process personal data in accordance with those interests where they are not overridden by your data-protection interests or fundamental rights and freedoms.

Our legitimate interests generally include:

• Provide you with requested callthree and Route66 Health Products and Services.
• Provide you with customer service and support, including to send you messages and provide user support, and to facilitate other communications that you request or are required to render our Products and Services to you. This may include providing you with information about new products and other opportunities we offer that we believe may be of interest to you based upon your interactions with us, and to personalize, measure, and improve such offers.
• Maintain and improve the quality of the callthree and Route66 Health Platform and the Products and Services that we offer through our Platform, including to customize our sites and products to better fit your needs as a user, develop new sites and products, to perform internal analytics for new and existing products (such as our user accounts and related features) and to conduct research and development. This also includes sharing personal data with our trusted service providers that provide services on our behalf.
• Protect you and others and to create and maintain a trusted environment, such as to ensure compliance our agreements with you and other third parties, to ensure safe, secure, and reliable sites and products, and to detect and prevent wrongdoing and crime, assure compliance with our policies, and protect and defend our rights, interests, and property. 
• Provide, personalize, measure and improve our marketing, including to send you promotional messages and other information that may be of interest to you with your consent. We may also use personal data to understand our user base and the effectiveness of our marketing.  This processing is done pursuant to our legitimate interest in undertaking marketing activities to offer products or services that may be of interest to you.
• For risk management purposes, including compliance with our legal and regulatory obligations and for fraud detection, prevention and investigation, including “know your customer,” anti-money laundering, conflict and other necessary onboarding and ongoing client checks, due diligence and verification requirements, credit checks, credit risk analysis, compliance with sanctions procedures or rules, and tax reporting.
• Comply with laws and regulations applicable to us, including any legal or regulatory guidance, codes, or opinions and to other legal process and law enforcement requirements, including any internal policy based on or reflecting legal or regulatory guidance, codes, or opinions. We may also respond to subpoenas, court orders, or legal process, and establish and exercise our legal rights or defenses against legal claims. 

1. Your privacy rights

In certain circumstances, individuals located within the EEA and UK may have the following data protection rights regarding their personal data:

• Right to access. You may have the right to request confirmation of whether callthree and Route66 Health processes personal data relating to you, and if so, to request a copy of that personal data.
• Right to rectification. You may have the right to request that callthree and Route66 Health correct or update your personal data that is inaccurate, incomplete or outdated.
• Right to deletion. You may have the right to request that callthree and Route66 Health erase your personal data in certain circumstances provided by law.
• Right to restrict processing. You may have the right to request that callthree and Route66 Health restrict the use of your personal data in certain circumstances.
• Right to object to processing. You may have the right to object to callthree and Route66 Health’s processing of your personal data, under certain conditions.
• Right to data portability. You may have the right to request that callthree and Route66 Health export the data that we have collected to you or another company, under certain conditions.

Where the processing of your personal data is based on your previously provided consent, you have the right to withdraw your consent at any time.  If you would like to exercise any of these rights, please submit a written request to support@callthree.com. We will respond to these requests in accordance with applicable data protection laws. We may ask you to verify your identity in order to help us respond efficiently to your request.

You may also have the right to lodge a complaint about our data collection and processing actions with the appropriate supervisory authority.  If you are in the European Economic Area, you can view the contact information for your data protection authority here.  If you are in the United Kingdom, please visit this page.

1. Retention of personal data

We will retain personal data for as long as needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods include:  (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

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1. Changes to this Privacy Policy

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We may change this Privacy Policy from time to time to reflect new services or changes in our data practices or relevant laws. The “effective date” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes are effective when we post the revised Privacy Policy on the callthree and Route66 Platform, including the Websites. We may take reasonable measures to notify you via email and/or a prominent notice on our Platform prior to certain changes becoming effective, and will update the effective date at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes.

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1. Contact Us

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Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to support@callthree.com